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Competition and Regulation of Mobile Money Platforms in Africa: A Comparative Analysis of Kenya and Uganda


We analyze the competition issues in mobile money in Kenya–where Safaricom is the market leader–and in Uganda: where the market is duopolistic. We evaluate the multi-sided platform characteristics that have underpinned the rapid growth of the lead mobile money platforms and that also imply that the market leaders have substantial market power and can act as gatekeepers. The conduct of the lead firms is assessed along with competition measures and regulatory interventions made in each country. The analysis highlights the importance of–and challenges for–competition enforcement in developing countries to ensure effective rivalry while realizing the gains from innovation in digital platforms.

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Fig. 1

Source: Compiled from data from the Central Bank of Kenya

Fig. 2

Source: Communications Authority of Kenya

Fig. 3

Source: Central Bank of Kenya Annual Reports, 2007–2018

Fig. 4

Source: Bank of Uganda

Fig. 5

Source: Macmillan Keck Attorneys & Solicitors (2018)

Fig. 6

Source: Compiled by authors from publicly available data posted on pricing

Fig. 7

Source: Compiled by authors from publicly available data posted on pricing

Fig. 8

Source: Authors’ calculations based on publicly available pricing data


  1. The Communications Authority of Kenya has the same acronym, and this can lead to confusion.

  2. World Bank, World Development Indicators database, accessed 6 April 2021.

  3. Other estimates place the significance relative to GDP at even higher levels (Lashitew et al., 2010; Tyce, 2020).

  4. See accessed 23 March 2021.

  5. Unstructured Supplementary Service Data (USSD) is a protocol that is used by GSM cell phones to communicate with their service provider's computers via text messages in a session that is opened between devices. Short Message Service (SMS) is a text message service that uses standardized communication protocols. Note that this is simply via feature phones, which the majority of the population can afford, and is distinct from internet and app-based banking that uses smart phones.

  6. The UK’s Vodafone Group Plc was a 40% shareholder in Safaricom at the time; 35% of the shares were transferred to its associated company South African listed Vodacom in 2017, with 5% retained by Vodafone.


  8. Tangaza Pesa was launched in January 2011 and in 2014 acquired an MVNO license roaming on Airtel Kenya’s network; Mobikash was launched in 2011 and provided mobile money transfer and mobile payment services to its customers.

  9. Interview conducted with the Competition Authority of Kenya, 12 August 2019.

  10. See CAK (2016) for average account values in banks.

  11. This interest charge was framed as a ‘fee’ of 7.5% for the 30-day loan, which equated to an annual interest charge of above 100% and well above the interest rate cap of 14% that was set by the Central Bank in 2016 (Tyce, 2020).

  12. Interview with Safaricom, 5th October 2018.

  13. Based on data from the annual reports of MTN and Airtel in 2019.

  14. Interview conducted with Financial Sector Deepening Uganda, 18th January 2019.

  15. The median transaction size is based on a nationally representative Financial Inclusion Insights Tracker Survey of 3000 adults, aged 15 and older, which was conducted in Kenya (InterMedia, 2014).

  16. We do not have data on the median transaction size in Uganda.


  18. Interview conducted with Safaricom M-Pesa agent, 4 October 2018.

  19. MTN Group Limited Interim financial results for the six months ended 30 June 2018, available at:

  20. The civil court judgment granted an award of UGX 800,000 in general damages and UGX 1.5 billion in punitive damages to EzeeMoney for MTN’s engagement in anticompetitive practices.

  21. It appears that dual-sim handsets grew in popularity

  22. Simon Roberts was involved in providing expert economic analysis to the CAK for the inquiry.

  23. Interview conducted with CAK, 12 August 2019.

  24. Simon Roberts was involved in providing expert economic analysis for the study.

  25. Based on data that are available from publicly available sources and MacMillanKeck (2018) taking into account the MTN charges and commissions for cash in, transfer and cash out.

  26. Bernard Murage v Fineserve Africa Limited & 3 others [2015] KLR, delivered 29 May 2015.

  27. Interview conducted with Equity Bank, 18th January 2019.

  28. On the role of market inquiries in Kenya, South Africa, and the UK see, respectively, Kariuki and Roberts (2016), Bonakele et al. (2022), and Fletcher (2022).

  29. The Financial Institutions (Agent Banking) Regulations, 2017.

  30. Interview conducted with EzeeMoney, 8 August 2019.

  31. Interview conducted with BOU, 14 January 2019.

  32. Interviews conducted with Pegasus, 8 August 2019; UTL, 18 January 2019.



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We are grateful for the very helpful comments of the journal’s referees. Support of South Africa’s National Research Foundation (Grant Number: 121104) is gratefully acknowledged for doctoral research that formed a basis for this paper.

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Correspondence to Simon Roberts.

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Paelo, A., Roberts, S. Competition and Regulation of Mobile Money Platforms in Africa: A Comparative Analysis of Kenya and Uganda. Rev Ind Organ 60, 463–489 (2022).

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  • Mobile money
  • Competition policy
  • Digital platforms
  • Kenya
  • Uganda
  • Economic regulation